What 2 Recent OFAC Cases Say About Compliance Priorities

Law360 (August 19, 2019, 3:02 PM EDT) -- On Aug. 8, the U.S. Department of the Treasury’s Office of Foreign Assets Control issued findings of violation to two U.S. companies in relation to administrative subpoenas with follow-up responses deemed by OFAC to be inaccurate or incomplete.

This type of enforcement activity has been undertaken by not only OFAC in the enforcement of U.S. sanctions regimes, but also by the Directorate of Defense Trade Controls and the Bureau of Industry and Security in the enforcement of U.S. export control laws.

To mitigate the risk of enforcement action, companies should develop detailed and stringent internal investigation procedures; ensure material statements are accurate...

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